Darren Wilson's Admissions in Response To Civil Lawsuit Filed by Michael Brown's Family

Case: 4:15-cv-00831-ERW Doc.
#: 165 Filed: 12/28/16 Page: 1 of 3 PageID #: 1737
UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF MISSOURI
EASTERN DIVISION
MICHAEL BROWN, SR., AND LESLEY )

McSPADDEN, )
)
Plaintiffs, )
) Cause No: 4:15-cv-00831-ERW
vs. )
)
CITY OF FERGUSON, MISSOURI, ) JURY TRIAL DEMANDED
FORMER POLICE CHIEF THOMAS )
JACKSON, AND FORMER POLICE )
OFFICER DARREN WILSON, )
)
Defendants. )
JOINT NOTICE OF FILING EXHIBIT A TO PLAINTIFFS

RESPONSE TO MOTION TO COMPEL
COME NOW, Plaintiffs Lesley McSpadden and Michael Brown, Sr., and files Exhibit
A to Plaintiffs Response to Motion to Compel that was inadvertently not attached to the initial
filing.
Dated this 28th day of December, 2016.
Respectfully submitted,
/s/Jasmine Rand
Jasmine Rand
RAND LAW, L.L.C.
2525 Ponce de Leon Blvd., Ste. 300
Miami, Florida 33134
Phone: (305) 906-0040
Fax: (305) 503-9235
Appearing Pro Hac Vice for
Plaintiff McSpadden
1
Case: 4:15-cv-00831-ERW Doc. #: 165 Filed: 12/28/16 Page: 2 of 3 PageID #: 1738
/s/Benjamin Crump
Benjamin Crump
Parks & Crump, LLC
/s/ Daryl D. Parks
Daryl D. Parks
Parks & Crump, LLC
240 N. Magnolia Drive
Tallahassee, FL 32301
Phone (850) 222-3333
Fax (850) 224-6679
jasminerand@gmail.com
bcrump@parkscrump.com
dparks@parkscrump.com
Plaintiff McSpadden
/s/ Ronald S. Sullivan

Ronald S. Sullivan, Jr., Esquire
1585 Massachusetts Avenue
Griswold 210
Cambridge, MA 02138
Phone (617) 496-4777
Fax (617) 496-2777
prof.ron.sullivan@gmail.com
Plaintiff McSpadden
Johnson Gray LLC

/s/Anthony D. Gray
Anthony D. Gray, 51534

7710 Carondelet Ave., Suite 303
Clayton, MO 63105
Phone (314) 385-9500
Fax (314) 594-2052
agray@johnsongraylaw.com
Appearing for Plaintiff Brown
CERTIFICATE OF SERVICE
I hereby certify that a copy of the foregoing was served on this 28th day of December, 2016,
a notice via electronic mail on the same day upon attorneys of record.
2
Case: 4:15-cv-00831-ERW Doc. #: 165 Filed: 12/28/16 Page: 3 of 3 PageID #: 1739
/s/Jasmine Rand
Jasmine Rand
Admitted Pro Hac Vice for
Plaintiff Lesley McSpadden
3
Case: 4:15-cv-00831-ERW Doc. #: 165-1 Filed: 12/28/16 Page: 1 of 21 PageID #: 1740
EXHIBIT A
UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF MISSOURI
EASTERN DIVISION
MICHAEL BROWN, SR., AND LESLEY

McSPADDEN,
Plaintii,
Cause No: 4: 15-CV0083 1-ERW
CITY OF FERGUSON, MISSOURI, JURY TRIAL DEMANDED

FORIMER POLICE CHIEF THOMAS
JACKSON, AND FOMER POLICE
OFFICER DARREN W.SON,
Defendants.
DEFENDANT DARREN WILSONREPOES T0

PLA, FST SET OF REQUESTS FOR ADMISSIONS
COMES NOW Defendant Darren Wilson, by and through his undersigned counsel, and
for his Responses to PlaintifFirst Set of Requests for Adrnissions, StateS:
l.On August 9, 2014, yOu (Darren Wilson) were empIoyed as a law enforcement ocer
With the Ferguson Police Department.
RESPONSE: Admitted.
2.On August 9, 2014, at the time you encountered Michael Brown, Jr., yOu Were On duty as
a law enforcement ocer for the City of Ferguson and was acting at all times, during the
Sject incident, Within the course and scope of your empIoyment with said department.
RESPONSE: Admitted.
3On August 9, 2014, at the time you encountered Michael Brown, yOu Were On duty as a
law enforcement ocer for the City of Ferguson, Ferguson Police Department, and you
Were aCting at all times during the subject incident, under coIor of law.
RESPONSE: Admitted.
4On August 9, 2014, Defendant Thomas Jackson was ultimately responsible for your
SuPervision.
01499675.DOCX; 1 )
RESroNSE: Denied as phrased The City of Ferguson City Manager has
SuPerVisory authority over Thomas Jackson.
On August 9, 2014, When you first encountered Michael Brown and Dorian Johnson, yOu
Were driving a marked paOI vehicle owned by Ferguson Police Department.
RESPONSE: Admitted.
6.On August 920 14When you first encountered Michael Brown and Dorian Johnson, they
Were located on Canfield Drive.
RESPONSE: Admitted.
7.On August 9, 2014, When you first encountered Michael Brown and Dorian Johnson, they
CroSSing Canfield Drive in an eastward direction.
RESroNSE: Admilted on August 9, 2014, When Irst encountered Michael Brown
and Dorian Johuson, they were walking on Caneld Drive in an
eastward direction. Denied a to the remainder of this request.
8.On August 92014, When you first encountered Michael Brown and Dorian Johnson, they
Were nOt aCtively engaged in any criminal activity.
RESPONSE: Denied.
9.On August 92014When you first encountered Michael Brown and Dorian Johnson, yOu
approached them in your marked patroI vehicle while traveling west on Canfield Drive.
RESPONSE: Admitted.
10.Before you said anything to themyOu had not communicated to any person or entity via
radio or telephone that you were about to address two individuals.
RESPONSE: Admitted.
1 l.On August 9, 2014, When you first encountered Michael Brown and Dorian Johnson, they
did not verba11y cormunicate anything to you before you said something to them.
RESPONSE: Admitted.
12.On August 9, 2014, When you first encountered Michael Brown and Dorian Johnson,
your first words were Get the fuckout ofthe street or on the sidewalk.
RESPONSE: Denied.
13.On August 9, 2014, When you first encountered Michael Brown and Dorian Johnson, yOu
used profanity directed at them.
(0149,673,DOCX; 1 )
RESPONSE: Defendant oects on the grounds this is vague as to time. At one
POinl in time during the suect encounter, I stated to Michael Brown,

Get theck back."
14.On August 9, 2014, after making a verbal statement to Michael Brown and Dorian
Johnson, yOu COntinued to drive several yards westward on Canfield Drive.
RESPONSE: Defendant objects on the grounds this is vague with respect to time.
Subject to this objection and during the suhiect encounter, denied.
15.From the time you first encountered and spoke to Michael Brown and Dorian Johnson,
you did not corrmunicate anyng to any person or entity via radio or telephone.
RESroNSE: Defendant objects on the grounds this is vague with respect to time.
Subject to this oection and during the subjeet encounter, denied.
16.On August 9, 2014, after making a statement to Michael Brown and Dorian Johnson and
driving several feet westward on Canfield Drive, yOu then stopped your vehicle and
Placed it in reverse.
RESroNSE: Denied, aS Phrased. I did not drive ``severafbet westward on
Caned Drive,aer making aStatement tO Michael Brown and
Dorian Johuson. At one point in time during the suect encounter, I
StOPPed my patroI vehicle and placed it in reverse.
17.After you placed the car in reverse, yOu then began backing up to their location.
RESPONSE: Admitted.
18.At the time you made this decision, Michael Brown and Dorian Johnson were not
actively engaged in any criminal activity.
RESPONSE: Denied.
19.Before you began to back up, yOu did not request assistance because you believed
Michael Brown or Dorian Johnson had committed crime.
RESPONSE: Denied.
20.On August 9, 2014, yOu reVerSed your vehicle to where Michael Brown and Dorian
Johnson were continuing to walk.
RESPONSE: Admitted.
21.You then maneuvered the vehicle at an angle in the middle ofthe street.
RESroNSE: I stopped my patroI vehicle at an angle near the middle of the street.
01499675.DOCX;1 )
22.At this time you did not communicate anything via radio or telephone to any person or
entity.
RESPONSE: Objection on the ground this is vague with respect to time. Subject
to this oection: Before I stopped my patroI vehicle at an angle in the
Street, I communicated with dispatch via radio. When I stopped my

PatrOI vehicle at an angle in the street, I did not communicate
anything via radio or telephone to any person or entity. In addition,
immediately aer therst round was discharged, I attempted to
COmmunicate by my walkie to dispatch. After the last round was

discharged, I attempted to communicate by my walkie to dispatch. I
later requested an ambulance to come to Caneld Drive.
23.At this time youdid not requestbackup.
RESroNSE: Objeetion on the grounds ts is vague with respt tO time. Sueet
to this oection: Before I stopped my patroI vehicle at an angle in the
Street, I requested backup. When I stopped my patroI vehicle at an

angIe in the street, I did not requet back up aga. In addition,
immediately after therst round was discharged, I attempted to
request backup by my walkie to dispatch. Aer the last round was
discharged, I attempted to do the same.
24.You thenplaced the vehicle in the park.
RESPONSE: Defendant oects on the grounds this is vague with respect to time.
Denied to the extent I did not place my vehicle in a park. Subject to

this objection and with respect to placing my vehicle in park, and
during the subject encounter, I placed my patroI vehicle in park.
25. In the stopped position the vehicle was seml-Pexpendicular toe seet.
RESPONSE: Defendant objects on the grounds semi"PerPendicular is vague and

COnfusing, and is therefore unable to respond to the same. I stopped
my vehicle at an angle neither parallel nor perpendicular to Caneld
Drive.
26.You stopped the vehicle in such a way as to blockade the path of Michael Brown and
Dorian Johnson.
RESPONSE: Denied, aS Phrased. I stopped my vehicle at an angle to cut o
Michael Brown and Dorian Johnson and to keep them OmeWhat
contained.
27.Had Michael Brown and Dorian Johnson continued to cross the street in the same
direction just before you reversed your vehicle,ey would have walked intoe drivers
door of your vehicle.
(0149%75.DOCX;)
RESPONSE: Denied.
28.You tOPPed the vehicle in cIose proximity to Mchael Browns body.
RESPONSE: Defendant objects on the grounds the ter``close proximity is vague
and relative. Subject to this oection and as I understand the term,
admitted.
29.Youdidnottumyourcaroff
RESPONSE: Defendant oects on the grounds this is vague as to time. Suhiect to
this and with respect to stopping my patroI vehice after I placed it in
reverse but before the end of the encounter, admitted.
30.You opened your car door and it came into contact wMchael Browns body.
RESPONSE: Admitted.
31.After it came into contact wMichael Browns bodyt ricocheted back on you.
RESPONSE: Denied.
32.At this time, yOurbodywas still inside ofthe vehicle.
RESroNSE: Defendant ohiects on the grounds this is vague as to time. Subjeet to

this and with respect to aer Irst attempted to open the door but
before Michael Brown slammed the door shut, admitted.
33.During this encounter, yOu reaChed through the car window.
RESPONSE: Admitted.
34.Duringis encounter you grabbed for Mchael Browns body.
RESPONSE: Admitted.
35.Dings encounter you gral)bed for Mchael Browns cIoing.
RESPONSE: Denied.
36.You eventua11y grabbed Mchael Browns foream.
RESPONSE: Admitted.
37.You eventua11y grabbed Mchael Browns t-Shirt.
RESPONSE: Denied.
(01 49675.DOCX; 1
38.Michael Brown never tried to remove your gun from your hoIster.
RESPONSE: Admitted.
39.The hoIster you carry is designed to prevent someone from easily pulling your weapon
from the hoIster.
RESPONSE: Admitted.
40You eventually decided to draw your gun from the hoIster and point it at Michael Brown.
RESPONSE: Admitted.
4l.Before drawing your weapon, Michael Brown had not displayed any weapon.
RESPONSE: Objection on the grounds the tem ``weapon,, is vague. To the extent
MichaeBrownbody (including his fists) constitute ``weapons,,, this is
denied.
42.Before drawing your weapon, Michael Brown had not displayed anyreatening oect.
RESPONSE: Objection on the grounds the term ``weapon,, is vague. To the extent
Michael Browns body (including his fist) constitereatening
Oects, this is denied.
43.Before drawing your weapon, yOu did not attempt to move your vehicle to a different
POSition.
RESPONSE: Defendant oects on the grounds this is vague as to time. Suect to
this and with respect to after Irst attempted to open the door but
before Michael Brown slammed the door shut, admitted.
44.Before drawing your weapon, yOu did not attempt to raise your car window to shield
yoSel
RESPONSE: Admitted.
45.You did not have papper spray in the car at that time.
RESPONSE: Denied.
46.You did not draw yourpepper spray at that time.
RESPONSE: Admitted.
47.You did notpepper sprayMichael Brown at that time.
RESPONSE: Admitted.
(01 49675.DOCX; 1 )
48.You didnothave a taserweapon in the car at that time.
RESPONSE: Admitted.
49.You did not draw a taser weaponat that time.
RESPONSE: Admitted.
50.You did notuse ataserweapon on Michael Brown at that time.
RESPONSE: Admitted.
5l.You did nothave anyelectronic weapon inyour car at that time.
RESPONSE: Defendant oects on the grounds this is corfusing. Suect to this
Objection and with respect to an electronic controI weapon I TASER,

admitted.
52.You did not draw any electronic weapon at that time.
RESPONSE: Defendant objects on the grounds this is confusing as to the term

`èlectronic weapon.,,Subject to thisand wirespect to my
understanding of the term , admitted.
53.You did not use any electronic weapon on Michael Brown at that time.
RESPONSE: Defendant objects on the grounds ts is connlSg as to the term

`èlectronic weapon.Subject to this and wirespect to my
understanding of the term, admitted.
54.You did not have a baton in the car at that time.
RESPONSE: Denied.
55.You did not draw a baton at that time.
RESPONSE: Admitted.
56.You did not strike Michael Brown with a baton at that time.
RESPONSE: Admitted.
57.You did not use your gun as a non-leal impact weapon to ske Michael Browns body.
RESroNSE: Defendant objects on the grounds this is vague. Suhjeet to this and to
the extent this requests whether I used myrearm as a blunt object to
Strike Michael Browns body, admied.
(01 49%73.DOCX; l
58.You did not use you fist to strike Michael Browns body.
RESPONSE: Admitted.
59.You could have driven your vehicle to a di3rent POSition before pulg your weapon
and pointing it at Michael Brown.
RESPONSE: Objection on the grounds this hypothetical question requests that

Defendant speculate, and is unable to truthIly admit or deny this
requesl accordingly.
60.You told Mchael Brown to gete fuck back as you pointed your weapon at him.
RESPONSE: Denied.
6l.At the time you blocked the path of Michael Brown and Dorian Jo1SOn, yOu had
COnducted a pedestrian stop of them.
RESPONSE: I attempted to make contact with Michael Brown verbally in order to

Stal and wait for backup to arrive. I reversed my vehicle in front of
Michael Brown and Dorian Johnson. Denied as to the remainder of

the reques`.
62.At the time you blocked the path of Michael Brom and Dorian Johnson, yOu had
COnducted a seizure of them.
RESPONSE: Denied.
63.You did not issue any verbal commands, Oeran gete fuckback,er you drew
your gun and prior to firing it.
RESPONSE: Denied.
64.Before you drew your gun and pointed it at Michael Brown, he had been trying to break
free from your grlP.
RESPONSE: Denied.
65.Before you drew your gun and pointed it at Michael Brown, he had been trying to flee.
RESPONSE: Denied.
66.You fired a shot at Michael Brown while you were sitting inside ofthe patroI vehicle.
RESPONSE: Admitted.
67.The first shot you fired at Michael Bromured him.
01 499675.DOCX; 1 )
RESPONSE: Admitted.
68.After you shot Michael Brown the first time he began to run away.
RESroNSE: Oection as this request is vague as to time. Subject to this, it i
admitted Michael Brown did not begin to run away until aer the
Shot wasred.
69.You fired another shot at Michael Brown as he ran away.
RESPONSE: Denied.
70.The second shot hit the building at 2960 Canfield Drive.
RESPONSE: Defendant has made a reasonable inquiry and the information it

knows or can ready obtain is insucient to enable him to admit or
deny this request for admission.
71.On August 9, 2014, a bullet from your weapon struck 2960 Canfield Drive.
RESPONSE: Defendant has made a reasonable inquiry and the information it

knows or can readiIy obtain is insucient to enable him to admit or
denyis request for admission.
72.You were never asked to explain how a bullet you fired at Michael Brown struck 2960
Canfield Drive.
RESroNSE: Objection on the grounds this requests information protected by the

attorney-Client privilege, aS this requests potential communications on
this topic between Defendant and his attomeys made in condence
regarding this matter. Subject to this objection, admitted.
73.You were never asked to explain how a bullet you fired at Michael Brown struck the
front of 2909 Canfield Drive.
RESPONSE: Oection on lhe grounds this requests information protected by the
attorney"CIient privilege, aS this requests potential communications on

this topic between Defendant and his attorneys made in condence
regarding this matter. Subject to this oection, admitted.
74.You did not communicate with any person or entity via radio or telephone until after you
fired the first shot from your gun at Michael Brown.
RESPONSE: Denied.
75 Immediately after you shot Michael Brown the first time, he began fleeing from your
Vehicle.
01 499675.DOCX; 1 )
RESPONSE: Denied.
76.When Michael Brown began fleeing from the vehicle, he wasming at full pace.
RESPONSE: Defendant object On the grounds the term ``full paceis vague and
relative, and is therefore unable to truthfully admit or deny this

request.
77.When Michael Brown began fleeing from the vehicle, he was rummg With his back
toward you.
RESPONSE: Admitted.
78.At some point after ruming at full pace away from you, Michael Brown sIowed to a stop.
RESroNSE: Defchdant objects on the grounds the term ``full pace,, is vague and
reative, and i therefore unable to trutIly adit or deny thisrst
POrtion of this request. Regardg the second portion of this request,

admitted.
79.After Michael Broun sIowed to a stop, he tumed around with his face and body in your
direction.
RESPONSE: Admitted.
80.At some point, Michael Brown raised his hands.
RESPONSE: Objection on the ground `raise his handsis vague. Subject to this
Objection, Michael Brown raised his hands to chest level between the
time I discharged myrst and second rounds in order to reenter the
Vehicle and continue the assault on me. To the extent this requests
raising his hands in the air at any other time, this is denied.
81.Sergeant Mudd questioned you at the scene ofthe shoog.
RESPONSE: Objection on the grounds ``quetionedis vague. Subject to this,
Sergeant Mudd asked me a question regarding wht happened.
82.You did not tell Sergeant Mudd that Michael Brown reached in his waistband with his
right hand as though he had a weapon.
RESPONSE: Admitted.
83.You eventua11y told Sergeant Mudd that Mchael Brown raised his ams duringe
encounter after tuming toward you.
RESPONSE: Denied.
10
01 499675.DOCX; 1
84.After tuming toward you, Michael Brown never placed his right hand in his waistband.
RESPONSE: Denied.
85.After tuming toward you, Michael Brown never indicated he had a weapon.
RESPONSE: Denied.
86.After tuming toward you, Michael Brown never came in phyical contact with you.
RESPONSE: 0eetion on the grounds this is vague with respect to time. Suect
to this oection and after Michael Brown ceased rurming away from
me and began running toward me, admitted.
87.After tuming toward you, Michael Brown did not indicate he was amed with any other
threatening oects.
RESPONSE: Denied.
88.After tuming toward you, Michael Brown did not wrestle with you over your weapon.
RESPONSE: Objection on the grounds ts is vague with respect to time. Suect
to this oection and after Michael Brown ceased running away from
me and began runng toward me, admitted.
89.After Michael Brown tumed toward you, yOu Were in a standing position and capable of
Physically maneuverlng.
RESPONSE: Oection on the grounds this is vague with respect to time. Subject
me and began running toward me, admitted.
90.You are trained in defensive tactics and techniques.
RESPONSE: Admitted.
91.After Michael Brown tumed toward you, yOu did not attempt any defensive tactics or
techniques.
RESPONSE: Objection on the grounds this is vague with respect to time. Subject
me and began running toward me, denied.
92.You did not attempt to hoIster your weapon and engage in any other non-lethal takedown
techniques to subdue Michael Broun.
0149%7.DOCX; 1 )
RESPONSE: Objeetion on the grounds this is vague with respect to time. Subject
to this oection and aer Michael Brown ceaed runng away from
me and began running toward me, admilted.
93.The claim that Michael Broun reached in his waistband with his right hand as though he
WaS gOing for a weapon is fabricated.
RESPONSE: Denied.
94.You fabricated this claim to justify the use ofdeadly force againt Michael Brown.
RESPONSE: Denied.
95.After Michael Brown took one step towards you, yOu began to fire at him.
RESPONSE: Oection on the grounds this is vague with respect to time. Suect
to this oection, after Michael Brown took the stutter step and before
he began to run, I did not discharge myrearm. At a point in time
after Michad Brown,s stutter step toward me and after he began to

run, I discharged myrearm.
96.At this time, Michael Brown had already been wounded bye first shot at your vehicle.
RESPONSE: Objection on the grounds this is vague with respect to time. Suect
to ts oection and up until the time Michael Brown began running
toward me, admitted.
97.Michael Brown was bleeding from that wound when he tumed around and faced toward
yOu
RESPONSE: Admitted.
98.BIood was dripping onthe pavement.
RESPONSE: Admitted.
99.You were never aked to explain the blood pattem on the pavement.
RESPONSE: Objection on the grounds this requests information protected by the

attorney-Client privilege, aS this requests potential communications on
this topic between Defendant and his attomeys made in condence
regarding this matter. Suect to this oection, admitted.
100. Mchael Brown sald, Dont shoot;after he tumed around.
RESPONSE: Denied.
101. Mchael Brown said, I dont have a gm, after he tumed around.
12
01499675.DOCX;1)
RESPONSE: Denied.
102. Mchael Brown said, Im unarmed, after he tumed around.
RESPONSE: Denied.
103. At the moment he firt tumed around, Michael Brown was several yards away from your
body.
RESPONSE: Oection on the grounds this is vague as to time and as to the term
``several yards., Suect to this objection and at the time Michael
Brown stopped running away from me and turned toward me, he was
SeVeral feet away from me.
104. You did not see any weapons on Michael Brown at any time from the first time you saw
Michael Brown walking down the street until the last shot you fired at him.
Michael Brown,s body (including his fists) constitute ``weapons,this
is denied.
105. You eventually leaned that Michael Brown did not have any type of weapon on him
While you were firing shots at him.
Michael Browns body (including his fists) constitute ``weapons,,, this
is denied.
106. Michael Brown was always unamed throughout the incident, and you fired your gun at
him several times.
RESPONSE: Admitted.
107. You have been trained in the use ofdeadly force.
RESPONSE: Admitted.
108. You have been trained in the use ofnon-deadly force.
RESPONSE: Admitted.
109. You fired a volley ofshots at some point after Michael Brown tumed toward you.
RESPONSE: Objection on the grounds the term volleyis vague and this is vague
With respect to time. Suect to this oection, Pertaining to the
Period of time after Michael Brown turned toward me and began

running toward me, and to my understanding, admitted.
13
(0 1 499675.DOCX; 1 )
l 10. Youred your weapon at least ten times throughout the incident.
RESPONSE: Admitted.
1 1 1. Your training requires that each shot be ajustified use ofdeadly force.
RESPONSE: Admitted.
1 12. One ofyour shots struck Michael Brown in the face.
RESPONSE: Admitted.
1 13. Michael Brown was not an imminent threat to you or anyone else after being shot in the
ce.
RESPONSE: Denied.
1 14. Mchael Browns body had begun to fall toe ground before you shot him in the face.
RESHONSE: Denied.
1 15. Mchael Browns body began fa11ing toe ground after you shot him ine face.
RESPONSE: Denied.
1 16. After shooting Michael Brown in the face, yOu Shot him in the top ofhis head.
RESPONSE: Admitted.
117. Before this shot, Michael Brown posed no imminent threat ofuury or death to you or
yOne ese.
RESPONSE: Denied.
118. Before shooting Michael Brown in the head, yOu had a clear line ofvision ofe top of
his head.
RESPONSE: Admitted.
1 19. You noticed blood on your hands at some time after killing Michael Brown.
RESPONSE: Admitted.
120. The blood on your hands was evidence.
RESPONSE: Admitted.
12l. You washed the blood offofyourhands.
14
01 499675.DOCX; 1
RESPONSE: Admitted.
122. The weapon you used to shoot Michael Brown was also evidence.
RESPONSE: Admitted.
123. You cleared your own weapon.
RESPONSE: Admitted.
124. After clearing your own weapon, yOu are able to leam how many times you fired it.
RESPONSE: Admitted.
125. You bagged yourownweapon.
RESPONSE: Admitled.
126. By bagging your own weapon, yOu COmPromised the evidentiary integrity ofthe weapon.
RESPONSE: Denied.
127. You were engaged to be married at the time ofthis incident.
RESPONSE: Admitted.
128. Your fiance was also empIoyed by the City ofFerguson.
RESPONSE: Admitted.
129. She was also a law enforcement ocer at some point for the City ofFerguson.
RESPONSE: Admitted.
130. She was your training ocer at Ferguson Police Department.
RESPONSE: Admitted.
13l. You were having sexual relations with her around the time ofthis incident.
RESPONSE: Oection on the grounds this is vague with respect to time. Suect
to this and subject to how I understand `àround the time of this

incidentto generally mean, admitted.
132. Your fiance was present when you washed the blood offofyour hands.
RESPONSE: Denied.
15
(01 499675.DOCX; 1 )
133 Your fianc6 was present when you bagged your gun.
RESPONSE: Admitted.
134. Your fianc6 did not tell you to stop washing the blood oofyour hands.
RESPONSE: Admilted.
135. Your fiance did not tell you to stop bagging the gun.
RESPONSE: Admitted.
136. Your fiance helped wash the blood offyour hands.
RESPONSE: Denied.
137. Your fianc6 helped bag the gun you used to shoot and kill Michael Brown.
RESPONSE: Object on the grounds the term ``helped,, is vague. Subject to this
Objection, aS I understand the phrase ``helped bag the gun,,, denied.
138. You are now married to your fomer fieldaining ocer.
RESPONSE: Admitted.
139.You have been trained about how much force is excessive force.
RESPONSE: Admitted.
140. You have been trained on how to use your hands and fists as a weapon.
RESPONSE: I have been trained on how to use my hands as a weapon, denied as to

the remainder of this request.
141. You have been trained on how to kick and use your legs and feet as weapons.
RESPONSE: I have been trained on how to use my knees as a weapon, denied as to

the remainder of this request.
142. You have beenained on the Fourteenth Amendment equal protection clause.
RESPONSE: Admitted.
143. You have been trained to treat Aican American citizens equnlly to oer citizens.
RESPONSE: Admitted.
144. You have been trained not to conduct unconstitutional stops.
16
0 1499675.DOCX; 1 )
RESPONSE: Admitted.
145.You have been trained not to conduct unconstitutional searches and seizures ofcitizens.
RESPONSE: Admitted.
146. You have been trained that parents have a consttional right to raise their children.
RESPONSE: Objection one grounds ``chiIdren,, is vague with respec=o whether
this refes to minor children or adt children. Suect to this
Objection and with respect to adt chdren, denied.
147. You have been trained that parents have a substantive due process right to a familial
relationship with their children.
RESPONSE: Objection on the grounds ``children,, is vague with respect to whether

this refers to minor children or adt chdren. Suect to this
Objection and with respect to adt children, denied.
148. You have been trained that you camot take a child from their parent at your will.
RESPONSE: Objection on the grounds ``cI]dren,, is vague with respect to whether
this refers to minor children or adt chiIdren. Suect to this
Oection and with respect to adult chiIdren, denied.
149. On the date ofthis incident, ChiefThomas Jackson, WaS One Ofyour supervisors.
RESPONSE: Admitted.
150. On the date ofthis incident, yOu Were following the use offorce policies ofthe Ferguson
Police Department.
RESPONSE: Admitted.
15l. One date of this incident, yOu Were following the customs of the Ferguson Police
Department.
RESPONSE: Objection on the grounds``customs,, is vague. Subject to thi
Objection and with respect to how I understand the term, admitted.
152. You have been foma11y accused of using excessive force against a citizen as a police
Ocer.
RESPONSE: Admitted.
153. You have been informally accused using excessive force against a citizen as a police
Ocer.
17
0 1 499675.DOCX; 1
RESPONSE: Admitted.
154. You have been fomally accused of racial discrimination towards a citizen as a police
ocer.
RESPONSE: Admitted.
155. You have made a racist remark while on duty as a police ocer.
RESPONSE: Denied as phrased. I have repeated a racist remark made by someone

eise, but I have not made a racist remark against anotherdividual
Whe on duty as a police oIeer.
156. You have usede word ``nigger to refer to an Afucan American on a=east one
OCCaSIOn.
RESPONSE: Admitted.
157. You haveheard a fellow ocer(s) at Ferguson Police Department use the word nigger
to refer to an African American on at least one occasion.
RESPONSE: Admitted.
158. You received an email in 2008 stating that President Obama would not be President for
Very long because: `twhat Afhcan- American man holds a steadyjob for four years.
RESPONSE: Denied.
159. You received an email in 201 1 depicting President Obama as a chimpanzee.
RESPONSE: Denied.
160. You received an email in 2011 statingat, An African-American woman in New
Orleans was admitted into the hospital for pregnancy termination. Two weeks later she
received a check for $5,000.00. She phoned the hospital to ask who it was from. The
hoapital said, Crimestoppers.
RESPONSE: Denied.
16l. You received an email in 201l with a photo ofa bare-Chested group ofdancing women,
apparently in Africa, Withe caption, `Mchelle Obanas High SchooI Reunion.
RESPONSE: Denied.
162.You described Michael Brown as the Incredible Hulk.
RESPONSE: Denied.
18
01499673.DOCX;1)
163"The Incredible Hulk is not a human being.
RESPONSE: Admitted.
164.You described Michael Brown as a demon or demon-1ike.
RESPONSE: Admitted.
165. A demonisnotahunanbeing.
RESPONSE: Admitted.
166. You did not view Michael Brown as a human being during this incident.
RESPONSE: Denied.
167. You have been fomally accused of unconstitutional stop(S) of a citizen on a prior
OCCaSIOn.
RESPONSE: Denied.
168. You have been foma11y accused of unconsttionally searching and seizing a citizen on
a prlOr OCCaSion.
RESPONSE: Denied.
169. You have been disciplined as a law enforcement ocer for misconduct.
RESPONSE: Admitted.
170. You have used your car to blockade the path ofa person on a prior incident.
RESPONSE: Object one grounds the term bIockade,, is vague. Subject to this
OIection, I have used my vehicle for purposesSuCh as to provide
COVer, limit mobrty of suspects, and provide space from a threat.
17l You were not trained to use your car to blockade the path ofcitizens.
RESPONSE: Object on the grounds the termblockade,, is vague. Subject to this
Objection, I have used my vehicle for purposes such as to provide

COVer, limit mobility of suspects, and provide space from a threat.
172. You have killed a person prior to Michael Brown.
RESPONSE: Denied.
173. You shot aperson prior to Michael Brown.
19
(01499675.DOCX;1 )
RESPONSE: Denied.
/s/ Peter J. Durme

PeterJ. Durme#31482
Robert T. Plunkert #62064

PITZER SNODGRASS, P.C.
Attomeys for Defendants City of Ferguson,
Missouri, Fomer Police Chief Thomas Jackson,
and Fomer Police O]cer Darren Wilson
lOO South Fourth Street, Suite 400

St. Louis, Missouri 63102-1821
(314) 42l-5545
(314) 421-3144 (Fax)
Email: dume@pspclaw.com
Email: Plunkert@pspclaw.com
A copy ofthe foregolng WaS emailed on this l lth day ofNovember, 2015, tO:
Anthony D. Gray Daryl D. Parks (PrO hac vice)

7710 Carondelet Ave., Suite 303 BeIjamin L. Crump (pro hac vice)
Clayton, Missouri 63 1 05 Jasmne O. Rand (PrO hac vice)
agray@j ohnsongraylaw. com 240 North Magnolia Drive

Telephone: 3 14-385-9500 Tallahassee, FIorida 3230 1
Fax: 3 14-594-2052 dp arks @pakscrump. com
Attomey for Plaintii bcrump @parks crump. co m
j as minerand@p ack s crump. com
Telephone: 850-222-333 3
Fax: 830-224-6679
Co-Counsel for Plaintif
/s/ Peter J. Durme
20
O1499675.DOCX;1

Darren Wilson's Admissions in Response To Civil Lawsuit Filed by Michael Brown's Family

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Darren Wilson's Admissions in Response To Civil Lawsuit Filed by Michael Brown's Family

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Case: 4:15-cv-00831-ERW Doc.

#: 165 Filed: 12/28/16 Page: 1 of 3 PageID #: 1737

UNITED STATES DISTRICT COURT

MICHAEL BROWN, SR., AND LESLEY )

JOINT NOTICE OF FILING EXHIBIT A TO PLAINTIFFS

Dated this 28th day of December, 2016.

/s/ Ronald S. Sullivan

Johnson Gray LLC

Anthony D. Gray, 51534

UNITED STATES DISTRICT COURT

MICHAEL BROWN, SR., AND LESLEY

Cause No: 4: 15-CV0083 1-ERW

CITY OF FERGUSON, MISSOURI, JURY TRIAL DEMANDED

DEFENDANT DARREN WILSONREPOES T0

for his Responses to PlaintifFirst Set of Requests for Adrnissions, StateS:

With the Ferguson Police Department.

RESroNSE: Denied as phrased The City of Ferguson City Manager has

SuPerVisory authority over Thomas Jackson.

Were located on Canfield Drive.

CroSSing Canfield Drive in an eastward direction.

RESroNSE: Admilted on August 9, 2014, When Irst encountered Michael Brown

and Dorian Johuson, they were walking on Caneld Drive in an

eastward direction. Denied a to the remainder of this request.

Were nOt aCtively engaged in any criminal activity.

radio or telephone that you were about to address two individuals.

used profanity directed at them.

RESPONSE: Defendant oects on the grounds this is vague as to time. At one

POinl in time during the suect encounter, I stated to Michael Brown,

Johnson, yOu COntinued to drive several yards westward on Canfield Drive.

RESroNSE: Denied, aS Phrased. I did not drive ``severafbet westward on

Caned Drive,aer making aStatement tO Michael Brown and

Dorian Johuson. At one point in time during the suect encounter, I

StOPPed my patroI vehicle and placed it in reverse.

actively engaged in any criminal activity.

Michael Brown or Dorian Johnson had committed crime.

Johnson were continuing to walk.

to this oection: Before I stopped my patroI vehicle at an angle in the

Street, I communicated with dispatch via radio. When I stopped my

COmmunicate by my walkie to dispatch. After the last round was

23.At this time youdid not requestbackup.

RESroNSE: Objeetion on the grounds ts is vague with respt tO time. Sueet

to this oection: Before I stopped my patroI vehicle at an angle in the

Street, I requested backup. When I stopped my patroI vehicle at an

immediately after therst round was discharged, I attempted to

request backup by my walkie to dispatch. Aer the last round was

discharged, I attempted to do the same.

24.You thenplaced the vehicle in the park.

Denied to the extent I did not place my vehicle in a park. Subject to

RESPONSE: Defendant objects on the grounds semi"PerPendicular is vague and

RESPONSE: Denied, aS Phrased. I stopped my vehicle at an angle to cut o

Michael Brown and Dorian Johnson and to keep them OmeWhat

door of your vehicle.

28.You tOPPed the vehicle in cIose proximity to Mchael Browns body.

RESPONSE: Defendant objects on the grounds the ter``close proximity is vague

and relative. Subject to this oection and as I understand the term,

RESPONSE: Defendant oects on the grounds this is vague as to time. Suhiect to

this and with respect to stopping my patroI vehice after I placed it in

reverse but before the end of the encounter, admitted.

32.At this time, yOurbodywas still inside ofthe vehicle.

RESroNSE: Defendant ohiects on the grounds this is vague as to time. Subjeet to

before Michael Brown slammed the door shut, admitted.

33.During this encounter, yOu reaChed through the car window.

34.Duringis encounter you grabbed for Mchael Browns body.